BSA-AML Compliance

Emerging Markets, Ltd. ("EML") is registered with FinCEN of the US Treasury Department as a Dealer in Foreign Exchange. EML maintains a professional and customized BSA-AML Compliance Program, and subjects all clients and foreign counterparties to comprehensive onboarding and monitoring due diligence procedures.  

United States federal law requires EML to comply with all applicable anti-money laundering (AML), anti-terrorist financing (ATF), and Bank Secrecy Act (BSA) rules and regulations. In this respect, EML seeks to maintain the highest possible standards of compliance with all applicable regulations.

Specifically, EML is required by federal law to maintain and implement an effective anti-money laundering (AML) and Anti-Terrorist Financing (ATF) compliance program suited to its business. Such a program must be commensurate with the risks posed by the location, type of customer, and nature and volume of the financial services provided by EML.

As part of its AML compliance program, EML has developed, administers and maintains a written program of policies and procedures that incorporates the "Four Pillars" of AML Compliance (per §352 of the USA Patriot Act), i.e. it has designated a knowledgeable Compliance Officer to administer the program, operates processes to monitor all transactions, provides periodic AML training to its employees, and conducts periodic, independent audits of its compliance program by Certified Anti-Money Laundering Specialists (CAMS).

EML's BSA compliance program includes procedures for bi-annual FinCEN registration, filing of Suspicious Activity Reports (SAR), filing of Currency Transaction Reports (CTR), record retention, and maintenance of know-your-customer profiles and client identification protocols.

These policies are intended to control EML's exposure to money laundering and terrorist financing risks inherent in the conduct of foreign exchange business. Correspondingly, EML has developed systematic procedures customized to its business and scale of operations to ensure and document compliance with its AML and ATF policies.

EML enforces a "zero tolerance" policy toward any customer, transaction, action, or omission that results in violation of applicable anti-money laundering laws or regulations.